IRS Form 5471 – IRS Form 5471 (Rev. December 2025) is an information return that certain U.S. persons—such as citizens, residents, domestic corporations, partnerships, estates, or trusts—must file when they are officers, directors, or shareholders in specific foreign corporations. It satisfies reporting requirements under IRC Sections 6038 and 6046, disclosing ownership, financial statements, income inclusions (like Subpart F and GILTI), earnings and profits (E&P), related-party transactions, and other details to ensure U.S. tax compliance on foreign activities.
Download the current form here: IRS Form 5471 PDF (provided link; Rev. December 2025).
Always refer to the latest Instructions for Form 5471 (also Rev. December 2025) for details: Instructions PDF.
Who Must File IRS Form 5471?
You generally must file if you are a U.S. person with at least 10% ownership (voting power or value, including constructive ownership under Section 958) in a foreign corporation that qualifies as a controlled foreign corporation (CFC) or specified foreign corporation (SFC) under Section 965, or in other triggering situations.
The IRS defines five main filer categories (check applicable boxes on the form; multiple categories may apply but only one Form 5471 per corporation is needed):
- Category 1: U.S. shareholders (≥10%) of a Section 965 SFC (subcategories 1a, 1b, 1c for unrelated/related constructive ownership).
- Category 2: U.S. officer/director when a U.S. person acquires stock creating ≥10% ownership.
- Category 3: U.S. person acquiring/disposing stock that crosses the 10% threshold (or becoming a U.S. person with such interest).
- Category 4: U.S. person with >50% control (voting power or value).
- Category 5: U.S. shareholder (≥10%) of a CFC (subcategories 5a, 5b, 5c; common for ongoing CFC ownership).
Exceptions include: multiple filers filing the same information (attach statement), certain constructive owners without direct interest, dormant foreign corporations (summary filing under Rev. Proc. 92-70), domestic election by foreign insurance companies, and no filing if no Section 958(a) ownership for foreign-controlled entities in some cases.
A separate Form 5471 (with applicable schedules) is required for each foreign corporation.
Filing Deadlines and Requirements
File Form 5471 annually as an attachment to your federal income tax return (Form 1040, 1120, 1065, 1120-S, 990, etc.), or partnership/exempt organization return, by the due date including extensions. It reports for the foreign corporation’s annual accounting period (tax year under Section 898) ending with or within your tax year.
For calendar-year filers reporting a 2025 foreign tax year, the deadline is typically April 15, 2026 (or extended date).
Key requirements:
- All information in English; amounts in U.S. dollars (translate using appropriate rates).
- Use reference ID number if no EIN.
- Complete all applicable lines and schedules based on your category.
Required Schedules and Key Information to Report
Different categories require different schedules. All require basic identifying info and Schedule G (other information). Categories 4/5 typically need financial schedules.
Common schedules include:
- Schedule A: Stock of the foreign corporation.
- Schedule B: Shareholders (U.S. persons ≥10% and direct shareholders).
- Schedule C: Income statement.
- Schedule F: Balance sheet.
- Schedule E/E-1: Taxes paid, accrued, or deemed paid (including foreign tax credits).
- Schedule H: Current E&P.
- Schedule I/I-1: Summary of shareholder’s income (Subpart F, GILTI, tested income, QBAI, etc.).
- Schedule J/P: Accumulated/Previously Taxed E&P (PTEP) accounts.
- Schedule M: Related-party transactions.
- Schedule O: Organization/reorganization, stock acquisitions/dispositions.
- Schedule G: Other information (new/updated lines on Top-up Taxes/GloBE, E&P changes from Section 304, functional currency/QBUs, etc.).
- Others like G-1, Q, R as applicable.
Key reported items: Ownership percentages and stock details, financial statements (income/balance sheet in functional currency and USD), pro rata shares of income, E&P balances and adjustments, related-party loans/dividends/transactions, debt instruments, high-tax/de minimis exclusions, hybrid dividends, and more.
Penalties for Failure to File or Incomplete Filing
Penalties are substantial:
- Section 6038: $10,000 per form per year per corporation; additional $10,000 for each 30-day period after IRS 90-day notice (max $50,000); plus up to 10%+ reduction in foreign tax credit.
- Section 6046: $10,000 per failure (similar escalation to $50,000).
- Other: Accuracy-related penalties, criminal penalties for willful failure, and potential disallowance of credits/deductions.
Corrected forms can be filed with an amended return (mark “Corrected”).
How to File?
Attach to your timely-filed (including extensions) original return. Electronic filing may be required in some cases. Use the most current revision and consult a tax professional for complex ownership structures or international tax issues.
Recent Updates (December 2025 Revision)
The form and instructions reflect changes from the OBBBA (Public Law 119-21, July 2025), including:
- Restrictions on CFC/SFC tax years (no more than 1 month deferral in certain cases post-Nov. 30, 2025).
- Updates to pro rata share transition rules for certain dividends.
- New/updated Schedule G questions (Top-up Taxes under GloBE/OECD rules, E&P changes from Section 304/PTEP, QBU/functional currency reporting with Form 8964-TRA attachment).
- Schedule E allocations, Schedule I-1 consolidation, and PTEP reclassifications.
No other major recent developments noted on the IRS page.
FAQs
- Do expats or green card holders need to file? Yes, if they meet ownership thresholds in foreign corporations.
- Is Form 5471 filed separately? No, attached to your income tax return.
- What if the foreign corp has no U.S. income? Still required if ownership thresholds are met.
- Can multiple people file one form? Yes, with proper statements for joint filers.
Consult a qualified tax professional or refer to IRS.gov/Form5471 for your specific situation, as international tax rules are complex and penalties severe. This article is for informational purposes and based on current IRS sources as of 2026.
For the official form and instructions, visit IRS.gov. Always use the latest versions to ensure compliance.